On behalf of Louisiana Environmental Action Network, the following comments are submitted. Prepared by Technical Advisor Wilma Subra.

Re: Sasol North America, Inc. Lake Charles Chemical Complex

14 Part 70 Air Operating Permits

2 PSD Permits

1 Water Discharge Permit

Environmental Assessment Statement

AI Number 3271

GTL and LCCP Air Permit Numbers and Activity Numbers PER 20130016 through PER20130031

Water Permit Number LA 0003336 and Activity Number PER20130015

Date: April 8, 2014

On behalf of Louisiana Environmental Action Network, the following comments are submitted.

Waste Water

The treated waste water from the existing and proposed Sasol Projects, as well as the waste water from the Axiall Vinyl Chloride Monomer Plant, are and will be discharged into the Calcasieu River. Storm water meeting LPDES permit limits will be discharged to Bayou Verdine.

The discharge from the new wastewater treatment system for the Gas to Liquids and Ethane Cracker projects, will be via a pipeline to the Calcasieu River. Some of the process wastewater from the Cracker project will be routed through the existing system and some will be routed through a new treatment system. Process effluent from the Gas to Liquids units will be treated in the new waste treatment system.

According to the Toxic Release Inventory, more toxic substances are currently discharged into Bayou Verdine (5,737.9 pounds per year) than into the Calcasieu River (4,217 pounds per year) by the existing Sasol facility. Such as excessive level of discharge of chemicals into Bayou Verdine is unacceptable.

Based on the information in the draft LPDES permit for the expanded Sasol facility, as much as 13,206 pounds of VOCs and 17,371 pounds of semivolatile organics for a total of over 30,000 pounds per year will be discharged each year into the Calcasieu River. Currently Sasol is reporting the discharge of volatile and semivolatile organics into the Calcasieu River at just over 2,000 pounds per year. The draft LDES permit will allow the discharge of more than 15 times the current rate of discharge of Volatile and Semi-volatile organic compounds into the Calcasieu River. Such a substantial increase in the discharge of toxic organics into the Calcasieu River is unacceptable.

Benzene, a known human cancer causing agent, will increase from 33 pounds per year to between 170 and 700 pound per year being discharged into the Calcasieu River. Ethyl benzene discharges will increase from 33 pounds per year to between 164 and 555 pounds per year. Toluene will increase from 33 pounds per year to 135 to 412 pounds per year. These increases in quantities of volatiles into the Calcasieu River are unacceptable.

The toxic heavy metals reported as being discharged into the Calcasieu River and Bayou Verdine by the existing Sasol facility consist of chromium, copper, lead, mercury, nickel and zinc Only nickel is require to meet discharge limits in the draft LPDES permit of 0.25 pounds per day as a monthly average and 0.59 pounds per day as a daily maximum. The current rate of discharge of Nickel is 116 pounds per year into the Calcasieu River and 119 pounds per year into Bayou Verdine. The new draft permit will allow from 91 to 215 pounds per year of nickel to be discharged into the Calcasieu River. There is a need for discharge limits to be established in the draft permit for chromium, lead and mercury.

The monitoring frequency requirements in the draft LPDES permit for VOCs range from one per two months to one per year. The monitoring frequency for all volatile and semivolatile compounds should be changed to once per two months as 24 hour composites. The discharge of such a large number of volatile and semivolatile organics must be required to be monitored on a more frequent basis to protect the quality of the surface water resources in the Calcasieu River system.

Inconsistencies

In the Environmental Justice Analysis, Sasol states “The new facility will be constructed in a sparsely populated area of the parish in an area zoned for industrial use that is already characterized by industrial facilities.” In the Environmental Assessment, Sasol states “The project will be located in an area that will be re-zoned for industrial development.”

Sasol states “Together, the GTL and Cracker projects are anticipated to create approximately 1,120 direct jobs. The projects will also generate 4,600 construction worker (jobs).” However, Sasol states there are 450 current workers at the facility and an additional 670 jobs will be added for the GTL and Cracker projects.” So it is not 1,120 direct jobs that will be created, but 670 direct job. The inconsistencies should be corrected.

Sasol’s Risk Management Plan

The initial Risk Management Plan for the Sasol Facility included the Toxic Chemical Worse Case Scenario for Ethylene Oxide, 290,000 pounds. The miles from the facility to the end of the vulnerable zone was 12 miles radius. The number of people at risk was 143,500.

Based on the information available on the current Sasol facility as of January 2011, the facility processes 557,063 pounds of toxic chemicals and 1,620,000 pounds of flammable chemicals for a total process amount of 2,177,063 pounds. The potential for off site consequences consist of five processes which include the above toxic and flammable quantities of chemicals.

The worst case scenario for the toxic chemical process associated with the Linear Alkyl Benzene Unit has 267,063 pounds of toxic chemicals. The two toxic alternative case scenarios are the Ethoxylation Unit which has 290,000 pounds of toxic chemicals and the Linear Alkyl Benzene Unit witch has 267,063 pounds of toxic chemicals.

The worst case scenario for the flammable chemicals consist of the Ethylene Unit which has 1,410,000 pounds of flammable chemicals and the Normal Paraffin Extract Unit with 200,000 pounds of flammable chemicals. The Normal Paraffin Extract Unit is also the unit associated with the alternative flammable scenario.

The Sasol process also consist of toxic chemicals associated with the Ethylene Oxide Unit with 290,000 pounds of toxic chemicals and hydrogen floride/hydrofluoric acid with 267,063 pounds of toxic chemicals. The flammable process chemicals in addition to those in the worst case and alternative case scenarios consist of 370,000 pounds of 1,3-butadiene, 260,000 pounds of propylene, 180,000 pounds of ethane, 300,000 pounds of ethylene, 220,000 pounds of pentane, and 10,000 pounds from the Alcohol Unit.

The Sasol Ethylene Storage Facility stores/processes 100,089,725 pounds of flammable chemicals with a potential for off site consequences from 1 process. The worst case scenario for the flammable chemicals consist of two chemical processes for the Ethylene Storage Facility which stores/processes 100,089,725 pounds of ethylene which results in two flammable worst case scenarios and one alternative case scenario. In addition propane is a flammable chemical that is stored/processed at 89,725 pounds at the Ethylene Storage Facility.

Based on the size of the Gas to Liquids and Ethane Cracker projects, and the 12 mile radius for the worst case scenario for Ethylene Oxide published in the initial calculation of worst case scenarios, there is a desperate need for the LADEQ to require Sasol to prepare a Risk Management Plan for the existing and proposed two new Sasol projects. The information on the Risk Management Plan and the worst case and alternative case scenarios and associated vulnerable zones must be made publicly available The vulnerable zone information is critical to the communities adjacent to the Sasol projects as well as the community at large in Calcasieu Parish.

The vulnerable zone information will be extremely helpful to the community members considering whether to relocate or stay in their homes. Based on the initial worst case scenario, the relocation area is not adequate to remove all individuals at risk. The communities in the new adjacent/ fenceline communities deserve to know their extent of risk based on the risk management information which must include the additional proposed Sasol projects .

Risk Screening Environmental Indicators

The Risk Screening Environmental Indicators (RSEI) for the current Sasol facility consist of ethylene oxide, benzene, 1,3-butadiene and the heavy metals chromium, nickel, mercury and copper. The ethylene oxide is the highest RSEI chemical and is a toxic Risk Management chemical stored and processed by the current Sasol facility and will be released as a toxic air pollutant by the proposed Ethane Cracker Project in excess of 20 tons per year.

1,3-butadiene is the third ranking RSEI chemical and is a flammable Risk Management chemical stored and processes by the current Sasol facility and will be released at a level of more than 11 tons per year by the proposed Ethane Cracker Project. Benzene is the second ranking RSEIchemical and will be one of the toxic Air Pollutants released in excess of 60 tons per year by the Ethane Cracker Project and in excess of 7 tons per year by the Gas to Liquids Project.

The fourth through sixth chemicals ranked in the RSEI for the current Sasol Facility are the heavy metals chromium, nickel and mercury. These are the chemicals discharged by the current Sasol facility and to be discharged by the new Sasol Projects into the Calcasieu River and Bayou Verdine. Only nickel has discharge limits. The ranking from the RSEI is another reason the quantities of these toxic metals in waste water should be controlled by discharge limits.

LEAN appreciates the opportunity to comment on the proposed Sasol Projects. LEAN would like to request to be notified of the final decisions on the permits.